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European Commission
Directorate-General for Information Society and Media
Unit E-6 Safer Internet and eContent
childsafetymobiles@ec.europa.eu
Answers on Child Safety and mobil phones services
12 October 2006
Enclosed please find the answers from The National IT and Telecom Agency in
Denmark. National IT and
Telecom Agency
The answers are our prelimenary remarks and are made on behalf of the official Holsteinsgade 63
level. They do not represent the Danish governmental attitude. DK 2100 Copenhagen Ø
Denmark
For your information the National IT and Telecom Agency is an agency under The Phone +45 3545 0000
ministry of Science, Technology and Innovation and has tasks like this: Fax +45 3545 0010
E-mail itst@itst.dk
• Advising users of IT and telecommunications Website www.itst.dk
• Advising companies etc. within the IT and telecommunications sector CVR no. 2676 9388
• Advising other relevant parties on current legislation and other general
matters concerned with IT and telecommunications
• Drafting Bills and Executive Orders E-mail @tst.dk
• Supervising and deciding matters regarding compliance with current
legislation in the IT and telecommunications sector
• Launching and implementing activities within the IT area for the purpose
of creating digital access and digital infrastructures in the public sector
• Promoting competition in the IT and telecommunications sector
• Ensuring the necessary consumer protection
In addition, the National IT and Telecom Agency handles contact to other
ministries, organizations, etc. in the area of information and communications
technology.
The National IT and Telecom Agency does not monitor IT security or other
security issues, but advises the Danish population. Typically in coorporation with
organisations like The Danish Media Council for Children and Young people.
Risks
1) Can you provide the Commission’s services with figures and examples on
risks raised by the use of mobile phones by children and young people?
Virus
There are not many recorded virus attacks on mobile phones. But as mobile phones
get more complicated and are equipped with operating systems as known in
computers, it is to be expected that the number of virus attacks will increase.
The known examples of malicious programs were directed against mobile phones
with operating systems, and both used Bluetooth to spread from one phone to
another.
Phising
The combination of SMS and Phishing is a new exploit, where the user receives a
text SMS message with a link. The link points to a false website and asks the user
to download a Trojan horse that takes control of the mobile phone.
Attitude towards security National IT and
Telecom Agency
In May 2006 the National IT and Telecom Agency asked the Danish population
what they found important when choising a mobile company. Besides price and a
good coverage 16 % said that secury was important.
The study also shows that security is an issue especially among young people and
older people. 19 % of the persons between the age of 15 and 19 mentioned security
as an important factor, while it was 22 % among the ones between 60 and 69.
Especially women seem to care about security.
The study was the first of its kind so we can’t tell whether the awareness is raising
or lowering.
The study doesn’t specify the meaning of “security”.
2) Do you see specific risks associated with the use of pre-paid cards, which
ones?
It could be a problem that it’s not possible to control what you have bought and
that some services are more expensive when you use a pre-paid card (typically a
higher charge per minute).
Regulatory framework
3) Please identify which of the above risks are not covered by the current
national regulatory, co-and self-regulatory framework
None.
4) Do you think the current balance between regulation/co-regulation and self-
regulation is the right one?
The Danish Government and the National IT and Telecom Agency is having an
ongoing focus on the subject and has so far taken initiative for establishing this
self-regulative actions: 2
• Handling of illegal content on the Internet
• Handling of safe chat
• Handling of mobile content services with associated payment
• Handling of SPAM
Handling of illegal content on the Internet
In November 2005, the National IT and Telecom Agency delivered a report to the
Ministry of Science, Technology and Innovation on the handling of illegal content
and censorship by Internet Service Providers. The report concluded that a number
of measures have been established in Denmark for fighting illegal content on the
Internet, including the following initiatives:
• Save the Children Denmark has established a hotline where child
pornography on the Internet can be reported, in accordance with the EU National IT and
Commission's Safer Internet Plus programme. Telecom Agency
• Internet service providers have established a code of conduct - describing
the procedures adopted by ISPs for removing child pornography etc. on the
Internet.
• The Media Council for Children and Young People and others have
initiated a number of information efforts in the area of possible measures
that should be taken by children and young people when navigating on the
Internet.
Finally the report concluded that Internet Service Providers (ISPs) in Denmark had
voluntarily launched initiatives to remove child pornography on the Internet.
The Internet Service Providers' work on fighting illegal content is still being
followed by the National IT and Telecom Agency within the framework of the ISP
group under the Danish IT Industry Association.
The National IT and Telecom Agency is also following the Safer Internet Plus
programme on a current basis to ensure that Danish initiatives are conducted within
the framework of the programme. This is done by comparing the Danish initiatives
with the recommendations of the Safer Internet Plus programme.
With regard to filter solutions, the report shows that other ISPs have followed the
steps of TDC and have established a filter against child pornography in cooperation
with Save the Children Denmark and the Danish National Police.
The report shows that there are a number of well-established initiatives in Denmark
to fight child pornography on the Internet, and that the vast majority of ISPs had
established a child pornography filter by the end of January 2006.
Handling of safe chat
In April 2006 the Minister of Science, Technology and Science encouraged the
Danish chat portals to establish a code of conduct describing the way they
support safe chat among children and young people. The code of conduct is now
on it’s way and is expected to be realized by the end of 2006. 3
The Association of Danish Internet Medias (FDIM) is coordinating the project, in
which Save the Children Denmark, the Danish Crime Prevention Council, The
National Commissioner and the Danish Media Council for Children and Young
People is participating.
A part of the project is to establish a kind of a trust mark. The mark is ment to
show the users of the site that the portal is following the code of conduct.
Another aspect is to inform children and parents about the new initiative.
The educational work will be developed in a coorperation between the National
IT and Telecom Agency and the participants of the code of conduct.
Handling of mobile content services with associated payment
National IT and
The Telecommunication Industries Association in Denmark has established a
Telecom Agency
framework agreement for mobile content services that is associated with payment.
The agreement was launched in May 2005 and is signed by the largest mobile
operators in Denmark.
The agreement states e.g. that premium rate services like SMS and MMS provided
in public series of phone numbers may not be unsuitable for children under the age
of 16, and that it may not contain e.g.:
• Descriptions of sexual or erotic matters
• Contact and dating services or numbers
• Games, prize competitions and similar services conflicting with the
applicable legislation.
Another issue dealed with is that the end user should be able to have constant
control over the cost of an order of games, competitions etc. Concerning legal
competitions the end user must never be able to participate by sending more than
25 SMS messages per day per service and that a service shall cease when the total
payment for premium charging reaches a specific (and relatively small) amount of
money.
The framework agreement also demands that only adults can get access to content
in the 16XX serie. The operator is required to satisfy itself that the end user
actually is an adult.
Handling of SPAM
Also initiated by the Minister of Science, Technology and Innovation the Danish
Internet providers agreed on protecting the users from SPAM. At the end of 2005
they established a code of conduct saying that the Internet providers should offer
the private users a central SPAM filter, and that they should provide informations
about the filter and how to protect yourself. They also agreed that it should be
possible for them to react towards customers sending SPAM.
Technical solutions
4
5) What measures do you recommend in the different areas described below,
and why?
5 a) Classification of commerciel content
No comments.
5 b) Opt-in/opt-out. Should the Opt-in (where the user has to explicitely request
access to adult content rather by accessing it by default) approach be applied in
all EU countries?
Like the Safer Internet Plus programme the National IT and Telecom Agency
prefer a solution where children and young people as a starting point have access to
all content. Danish children as well as adult have a freedom of expression, and they
are traditionally raised to be – and are - critical consumers. National IT and
Telecom Agency
If the operators can offer an opt-in-solution, it’s up to them to inform the parents
and children about the possibility. Then it is the choice of the single parent.
5 c) Age verification: should Mobile network operators implement face to face
identity check to determine the age of the user? Should this process also be
applied when a customer buys a pre-paid card?
No comments.
5 d) Filtering and blocking systems. Should filtering systems be installed by
default when the subscription allows Internet access?
The National IT and Telecom Agency prefer a solution where it’s up to the parents
and the children to choose a filtering and blocking system. It should not be
installed by default.
The reason why is that the filtering and blocking systems potentially also filters out
contents of good value. Another reason for this attitude is that we consider dialogue
between parents and children to be the best preventive action.
5 e) Chat rooms. Should chat rooms accessible by children be moderated (in an
automatic way or by a person)?
The Danish chat providers are working on a code of content in which moderation is
a part of the code (See 4). The idea is to demand an automatical moderation of
chats between children and young people and to make it up to the providers
themselves if they would have a human moderator. Though if the chat room
establish a human moderator she or he has to be identified as a person without any
convictions related to child pornography.
5 f) Raising awareness among parents and children
5
The National IT and Telecom Agency finds that educational campaigns are the
essential initiative when it comes to the protection of children and young people.
In Denmark we allready have a lot of these activities. The Media Council for
Children and Young People arranges the Safer Internet Day once a year, the
National IT and Telecom Agency has a so called “Netsikker nu” day, also once a
year, and Save the Children Denmark runs a safer Internet site together with The
Danish Crime Prevention Council.
Besides this the Telecommunication Industries Association has produced
different kind of educational informations targetted children in Danish primary
schools and their parents.
With regard to information and education Denmark is in the top league of Europe -
still and very important though we are trying to find new ways to improve our
efforts. National IT and
Telecom Agency
5 g) Dedicated mobile phone packs for children, for which age group?
No comments.
Yours sincerely,
6
